BAPTISTE v. COMMISSIONER

Docket Nos. 383-90, 384-90.

100 T.C. 252 (1993)

GABRIEL J. BAPTISTE, JR., TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT RICHARD M. BAPTISTE, TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 29, 1993.


Attorney(s) appearing for the Case

Paul J. Peter, for petitioners.

J. Anthony Hoefer, for respondent.


WHITAKER, Judge:

This matter is before the Court on respondent's separate motions for summary judgment filed pursuant to Rule 121.2 The issue for decision is whether petitioners are liable for interest under Federal law on the amount of their personal liabilities for unpaid estate tax from the due date of the transferor's estate tax return.

FINDINGS OF FACT

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